https://www.taxtmi.com/caselaws?id=763108 The ITAT Bangalore ruled in favor of the assessee regarding transfer pricing adjustments. The Tribunal held that the TPO must examine the specific character of IT support services provided by the assessee rather than treating them generically as ITeS. Regarding cost contribution charges, the Tribunal directed deletion of additions, finding the TPO's application of CUP method flawed as it failed to identify comparable uncontrolled transactions as required under Rule 10B(1)(a). The TPO's rejection of TNMM and determination of arm's length price at nil was overturned, with the Tribunal noting the assessee had supportive evidence for its claims. en-us Tue, 07 May 2024 00:00:00 +0530 Thu, 12 Dec 2024 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763108 The ITAT Bangalore ruled in favor of the assessee regarding transfer pricing adjustments. The Tribunal held that the TPO must examine the specific character of IT support services provided by the assessee rather than treating them generically as ITeS. Regarding cost contribution charges, the Tribunal directed deletion of additions, finding the TPO's application of CUP method flawed as it failed to identify comparable uncontrolled transactions as required under Rule 10B(1)(a). The TPO's rejection of TNMM and determination of arm's length price at nil was overturned, with the Tribunal noting the assessee had supportive evidence for its claims. Case-Laws Income Tax Tue, 07 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763108